Carinan Ezekiel Jacob D.

October 3, 2018
JD Block I Atty. Nashmyleen Marohomsalic
Legal Writing I

MACEDA AND MACEDA LAW OFFICES

U2604-B Philippine Stock Exchange East Tower Psg,
Brgy San Antonio, Pasig City, Metro Manila 1605
+63(2)7061262
zekejacob17@gmail.com

October 3, 2018

Atty. ABCD
Legal Eagles Condominiums
Makati City, Philippines

Attn: Atty. ABCD

Re: Demand to pay Angelica’s moral damages and to return her

rights to property lawfully and properly to her with compliance to
Republic Act No. 6552, also known as the “Realty Installment
Buyer Act” or Maceda Law

Atty. ABCD:

I write on behalf of our client, Ms. Angelica Anonuevo. Our client is the
rightful owner of Unit 123, Asia Bldg., Park Residences covered by CCT No. PT-
41289, 65.50 square meters. Based on our client's records, she has rights over this
property and she is in good standing.

The sum of her paid installments amount to more than two years, proving
her to be entitled for a grace period which gives her an opportunity to pay before a
notice of cancellation. The issuance of notice of cancellation was not proper for it
constitutes the refusal of you as a seller to enable her afford the grace period.

Our client mentioned to us that there is an ongoing communication and

unresolved complaint to you regarding your negligence to deliver its commitment
and why you did not even bother to reply and instead immediately padlocked the
unit. To protect her rights over the property in subject, I deem that she let be
informed about the status of your transaction first before she begins to be
submitted with a notice of cancellation.

Our client suffered moral damages in the light of this event as she and her
relatives were humiliated because of your improper treatment to her, padlocking
her out of a property which she has rights over. In addition the items that rightfully
belong to her were improperly intruded by your actions against her rights.
 In addition, the contract you wrote with her as a partner provides provisions
that are against her rights as provided by Maceda Law.

Our client is willing to pay the balance of the purchase price through a bank
loan, rather than continuously pay installments at a high interest rate of 18% per
annum through the in-house loan. Also, we demand you to entitle her to reliefs and
benefits to the said property as you and her may agree upon. These actions are all
to warrant your promise to acknowledge her rights over the property.

Should you deny the above requests, it is legally demandable that we will be
positive in enforcing our demands.

Our client firmly knows that under the Maceda Law, the guidelines that
should prevail on the contract between the unit buyer and the seller, and the rights
and reliefs entitled to her.

Otherwise, I shall immediately file a complaint in violation of R.A. No.

6552, also known as the “Realty Installment Buyer Act” or Maceda Law with
claims for actual damages, moral damages, exemplary damages,
fines, costs of suit, interests, penalties, etc., which based on my rough estimate
would be an additional Php 90,000.00 on top of the required amount.

Worse, you may be disbarred. We also plan to file an administrative

complaint against you to the Supreme Court or Integrated Bar of the Philippines as
your acts against our client manifest moral turpitude and taints your good moral
character.

Note that you have been duly warned and notified.

Atty. Ezekiel Jacob D. Carinan